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Johnson v. Comm'r of Internal Revenue

United States Tax Court
Mar 28, 2023
No. 4572-22S (U.S.T.C. Mar. 28, 2023)

Opinion

4572-22S

03-28-2023

PAUL HENNING JOHNSON & ANDREA PARKER JOHNSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Kathleen Kerrigan Chief Judge

On August 24, 2022, respondent filed in the above-docketed case a Motion To Dismiss for Lack of Jurisdiction as to Paul Henning Johnson, on the ground that no statutory notice of deficiency, as authorized by section 6212 and required by section 6213(a) of the Internal Revenue Code (I.R.C.) to form the basis for a petition to this Court, had been sent to petitioner Paul Henning Johnson with respect to taxable year 2017, nor had respondent made any other determination with respect to Paul Henning Johnson's tax year 2017 that would confer jurisdiction on this Court, as of the date the petition herein was filed. Although the Court directed petitioners to file an objection, if any, to respondent's motion to dismiss, petitioners have failed to do so. Accordingly, it is

ORDERED that respondent's Motion To Dismiss For Lack of Jurisdiction as to Paul Henning Johnson is granted. This case is dismissed for lack of jurisdiction as to Paul Henning Johnson, and references in the petition to Paul Henning Johnson are deemed stricken. It is further

ORDERED that the caption of this case is amended to read "Andrea Parker Johnson, Petitioner v. Commissioner of Internal Revenue, Respondent".


Summaries of

Johnson v. Comm'r of Internal Revenue

United States Tax Court
Mar 28, 2023
No. 4572-22S (U.S.T.C. Mar. 28, 2023)
Case details for

Johnson v. Comm'r of Internal Revenue

Case Details

Full title:PAUL HENNING JOHNSON & ANDREA PARKER JOHNSON, Petitioners v. COMMISSIONER…

Court:United States Tax Court

Date published: Mar 28, 2023

Citations

No. 4572-22S (U.S.T.C. Mar. 28, 2023)